JUDGMENT

Petitioner seeks relief from the burden of making a pre-

deposit under Section 86 of the Finance Act, 1994 (‘for short ‘the Act’) for preferring the appeal before the Central Excise and Service Tax Appellate Tribunal (CESTAT).

2. Petitioner is a proprietor of an establishment by name M/s. Swathi Constructions at Shoranur and is engaged in laying of power lines on behalf of persons, who had executed contracts with the Power Grid Corporation of India.

3. According to the petitioner, it had executed job works during various financial years and that all records and details were submitted to the jurisdictional ofÏcers under the Goods and Service Tax Act, 2017 as well as the Central Excise Act 1944. He further contended that after the coming into force of the CGST Act, an order was issued on 13.5.2019 levying penalty and service tax upon the petitioner under five different heads, imposing a huge liability upon the petitioner. Though the imposition of liability of service tax and penalty upon the petitioner was impermissible in the circumstances of the case, petitioner challenged the order of the Adjudicating Authority before the CESTAT. As per the provisions of Section 86 of the Fi